Dr Shaun Peck's presentation to the CRD Core Area Liquid Waste Management Committee - October 7th 2009.
Thank you for the opportunity to speak to you again.
My comments to-day are on agenda item Seven: Site Selection for Wastewater Treatment Facilities in Saanich East-North Oak Bay (SENOB), Core Area Wastewater Treatment Program (CAWTP).
I would like to thank the staff for providing me with a May 2009 report that provides a justification for a SENOB waste water treatment plant. Some of the reasons given in this report are no longer valid.
For example it was recently announced that the District of Oak Bay has received approval for 1/3/1/3 (Federal and Provincial) cost sharing (the funding that the Blue Bridge did not get) for its $7.5 Uplands low pressure system. This will reduce by 90% the inflow to the East Coast interceptor (900 Litres/Second) during wet weather flows.
In the May 2009 staff report there was no mention of the operating costs of the proposed plants and comparing it with the alternative – attenuation tanks (underground reservoirs) – that will prevent the sewarage system overflows during wet weathers. The operating costs of these tanks will be low.
There is no mention as to whether the proposed SENOB plant helps achieve what is believed to be the Federal and Provincial objective of a BOD of 25 ml/l and TSS or 25 mg/l. I understand that the plan would be for the sludge from the SNOB plant will be put back into the East Coast Interceptor and piped for treatment to the MacCaulay/McLoughlin site.
I still find the rationale of “creating opportunities for water reuse and heat recovery” troublesome – if there is no business case for it - in other words it just creates an add on cost for the taxpayers. The resource recovery options are nice objectives however you have heard in at least two reports that there is no clear market at this time and that there is unlikely to be a net benefit to the taxpayer.
Your new consultants Stantec have helped reduce the overall Capital Costs of the proposed Liquid Waste Management Plan amendment. In particular the removal of the Clover Point Wet weather plant (subject to senior government approval) - $68 Million – the equivalent of one Blue Bridge. Should not the consultants be requested also to review the rationale previously given for this SENOB plant.
If the SENOB plant was eliminated or deferred in the plan there would be a saving of somewhere between $125 and $150 Million in Capital Costs. (Two Blue Bridges). There will also be savings in the operating costs.
On September 23rd in the report you received it was noted that the carbon foot print for this proposed SENOB plant is much greater than the MacCaulay/McGloughlin or Westshore sites. The prime objective or any plant should be to reduce the carbon footprint not to just obtain carbon offsets. Offsets are created to balance needed carbon emissions or ones that already exist. Surely you should be aiming for the lowest carbon footprint. As an aside - The Economist reported this last week that “Canada has overshot Kyoto targets by 29%”.
The staff report on May 2009 did not mention the Carbon Footprint of the Attenuation tanks versus a Waste Water Treatment Plant.
My last comment to-day is on planning for future capacity. At last Saturdays workshop we heard that deciding the future capacity – the design flow - of a WWTF is open to all sorts of assumptions.
One question I have for you and the consultants – and this applies to all the planning - is how to anticipate water use by the increased population in the future – in the next 50 years ? Given that Victoria’s experience is that there is considerable water conservation occurring – what assumptions are being made of water use in the future – Sewage is 99% water – and that is what the plants are designed to treat. In my experience in the past the traditional approach to design used by Civil Engineers was to take an arbitrary figure of say 20 gallons a person a day. The important message for the consultants is to ensure that you calculate the current water use per household or even per person for the region using knowledge of the current and expected water use. There is a long history in the world of overdesign – an example would be the Boosterism that resulted in Winnipeg’s water system developed in the early part of the last century.
Thank you,
Dr Shaun Peck, Public Health Consultant,
Member of Responsible Sewage Treatment Victoria
Dr Shaun Peck's presentation to the CRD Core Liquid Waste Management Planning Committee - September 23rd 2009.
Thank you for the opportunity to speak to you again.
I will start by quickly reminding you that the CRD, the Province and the Federal Government have been informed of the judgments of ten professional marine scientists and six public health officials. The evidence is that there is minimal effect on the marine environment and no measurable public health risk from the current method of disposal of Victoria’s Liquid Waste by means of the two deep sea outfalls.
That being said I will address to-days report on the analysis of the options Agenda Item Six. http://www.crd.bc.ca/reports/corearealiquidwastem_/2009_/09september23_/ehq0995option1a1b1ca-1/EHQ09-95Option1a1b1cAnalysis,withSummaryReportAttached.pdf
With regards to resource recovery it is stated in to-days report: “The work completed to date indicates there is higher potential for recovery of resources than was identified in previous CRD studies.”
What we need to know is if resources are recovered is there a net add on cost? Will the resource recovery truly reduce the overall cost beyond the cost of using a technology that does not include a resource recovery option? Surely these questions should be answered.
To-days report states – “a greenhouse gases (GHG) assessment has been completed for all options. Carbon footprint analysis indicates that all options have the potential for a net negative carbon footprint depending on the degree of resource recovery implemented. A negative carbon footprint indicates a beneficial environmental impact related to GHG emissions.”
Well – does it benefit the environment ? What I would like to hear is how does this carbon footprint compare with the minimal carbon footprint that occurs with the current two deep sea outfalls.
It is all very well to create more carbon emissions and get offsets but that does not necessarily reduce the overall impact on the global environment. The objective should not be to create offsets but to reduce the primary emissions.
Offsets are created to balance needed carbon emissions or ones that already exist.
There will for example still be released a ton of Carbon Dioxide to the atmosphere for every ton of cement that is manufactured for the many tons of concrete in the treatment plants.
It is good news to see that the consulting team is recommending deferment or elimination of the wet weather facility at Clover point that would save $68 Million because of the infrequency of use. It is also good news that “The new expected capital costs are expected to be considerably lower than those developed by the previous consultants and are between $865 million and $965 million.”
The need for the Saanich East / North Oak Bay plant still should be questioned – there will be no significant population increase in that area. Some of the water may be able to be discharged at another deep sea outfall but the sludge will be piped for treatment to (I believe) the Mccaulay/McLoughlin site.
I note that there may now be three new deep sea outfalls bringing the total number to five. What effects will the additional outfalls have on the Marine Environment?
I would like to remind you of the latest detailed available cost estimates that your previous consultants generated of the proposed land based sewage treatment. The net present value, based on an analysis of the report the you submitted to the Minister of Environment in June this year (replacing $1.1 billion) is $2.3 billion - $1.1 billion for capital costs, and $1.2 billion for operating costs, both in 2008 dollars. This I believe is amortized over 25 years. The per household costs would be $1000 to $1400 per year.
To understand the magnitude of to-days slightly reduced suggested capital cost estimates – for $965 Million – fourteen Johnson Street Bridges ($69 Million) could be built rather than sixteen for the capital cost of $1.1 Billion of the proposed land based sewage treatment and 3.6 rather than four new Royal Jubilee Hospital towers ($269 Million capital cost). Few would argue the benefits to the community of these two projects.
The Federal Regulation has not yet been proclaimed. The proposed regulations are expected to be published in the Canada Gazette, Part I, in December 2009. After feedback is reviewed, the regulations will be revised and finalized in 2010. There is still an opportunity for the Federal Government, when reviewing the Fisheries Act Regulation to acknowledge Victoria’s unique Marine receiving Environment as they have for years in interpreting the Act and Regulations.
As a final note. We read daily of cut backs in Provincial funding to Health, Education the Arts and other public services. We read of the Federal Government running an increasing deficit. I find it bizarre that when every other level of government is trying to contain expenditures the CRD is planning to spend a vast amount of taxpayers money for no clearly defined benefit.
Thank you,
Dr Shaun Peck, Public Health Consultant,
Member of Responsible Sewage Treatment Victoria
Dr Shaun Peck's comments to the CRD's Liquid Waste Management Committee on July 22nd 2009.
Thank you for the opportunity to speak to you again.
To-day I would like to discuss Item 6 on your agenda “Program Management Consulting Services Work Program and fees” where there is a request to the committee for approval of $3,565,200 for the planning until March 31st 2010.
Since June 15th Stantec Consulting Ltd have been your new consultants on this project. I will reiterate some comments that I have made in the past. These comments are posted on the web site www.rstv.ca.
Firstly let me say that I continue to be concerned that in any triple bottom line analysis that there is no comparison with the present practice. Surely you should include a comparison with the present method of disposal - screening and discharge through two deep sea outfalls.
Including the biosolids with the solid waste is a worthy study but surely you should ensure the consultants come up with the economic analysis – is it going to cost the taxpayer more?
The same principle applies to the Wastewater heat recovery and delivery mechanism for James Bay. Will there be an economic analysis – is it going to add costs for the taxpayer?
The same principal applies to the heat recovery and water reuse with the University of Victoria.
There surely has got to be some cost benefit for carrying out these great ideas.
On a positive note all improvements in the “Inflow and Infiltration” – the “I and I” - are important measures and hopefully will be where the CRD and the member municipalities will continue to commit their budgets.
I was recently in Honolulu and met at the Mayor’s office with the staff from the department of Environmental Services. For years the US EPA have been trying to persuade Honolulu to install secondary treatment prior to their two deep sea outfalls. The potential cost is US $1 - $1.2 Billion. However there has been a lack of public health or marine science justification for the EPA’s orders.
Meanwhile I was intrigued to learn that in this year’s City and County of Honolulu budget they are spending millions on improving the sewerage infrastructure to prevent “I and I”. Honolulu is also spending US $1 Billion on a light rail transit project that will break ground later this year. (Reference: Office of the Mayor – Honolulu News, City and County of Honolulu. July 2009. www.honolulu.gov )
There are some lessons here for the CRD and member municipalities. Should not the priority for a massive expenditure of taxpayers money be on Light Rail Transit to the western communities, housing for the homeless, a new Johnson Street Bridge, health care facilities or at least some project that will improve the overall environment or the health and well being of the citizens. This is particularly so when there is no clear benefit from the CDN $1-2 Billion expected expenditure. This will add between $500- $700 to each householders taxes or user fees in the Core Area.
On March 25th the committee passed a motion “that staff be directed to request that the consultants prepare a least cost option for sewage treatment that will meet both the requirements of the Provincial Government and the standards agreed to by the Council of Environment Ministers.”
Options 1 A, B and C still include the Saanich East/North Oak Bay option using Membrane Filtration Technology. This technology has greater capital and operating costs and uses 2.4 times the energy of a conventional activated sludge technology. It is a given that there are lots of possibilities as to what you can recover – heat and energy etc - but surely you have to consider the net costs of doing this. Surely you should continue to ask for this least cost option - particularly in these economic times.
I would like to comment on the work planned for “Greenhouse gas offsets”. As you are aware producing a ton of cement releases a ton of carbon dioxide. There will be much energy use in land based sewage treatment plants and this will require “Greenhouse Gas Offsets’’. As with the triple bottom line surely you should compare the Greenhouse Gas emissions with the current deep sea outfalls where to the best of my knowledge the only Greenhouse Gas emissions are from the pumping stations and from the trucks that twice a week take the screenings to the Hartland Landfill.
The proposed land based treatment sewage treatment seems to have an open ended budget. There seems to be nothing that is holding back the development of new ideas with increasing costs that the taxpayer will be paying for. Should you not be asking tougher questions of your consultants to ensure that costs are kept under control?
Thank you,
Dr Shaun Peck,
Member Responsible Sewage Treatment Victoria.
Wednesday, July 22nd, 2009
Dr Shaun Peck's comments to the Core Area Liquid Waste Management Committee on June 10th 2009.
I will firstly address Item 6 on the agenda: “Inflow and Infiltration”. This report does not mention the outcomes to be achieved by this program. (It is more of a process report). I will explain what I mean. In any sewer pipe maintenance program it is important to prevent as much as possible inflow and infiltration into the sewerage pipe system. The greater the “I and I” the greater the flows that have to be managed. Older systems – such as Victoria, Esquimalt and Oak Bay have much greater “I and I” problems. If “I and I” is not controlled larger pipes are needed to dispose of the liquid waste. If we are going to have land based sewage treatment in the future the success (or outcome) of the “I and I” program will affect the size of the plants designed and will have an effect on how frequently there are sewer overflows into the storm drain systems and on to the beaches.
One aspect I am pleased to see in this report is the recognition of the importance of managing the sanitary sewerage overflow. Sanitary sewer overflows are releases of raw sewage into storm drains and/or local waterways. As in any sewerage system there are cross connections where sewage gets into the storm drain system and ends up on our beaches. These cross connections need to be managed and corrected. We have a public health problem from the sewerage around Victoria when you get these cross connections into the storm drain system and contaminated discharges (that contain potentially disease causing bacteria) into the creeks and storm drains. This is where human exposure can occur – such as children paddling in the Bowker Creek discharge – that I have observed, and other activities on the beaches.
Speaking now to Agenda Item 8. "Bylaw No. 3615, A Bylaw to Authorize Borrowing of $12 Million for the Estimated Cost of Works Relating to the Core Area and West Shore Wastewater Treatment Program - CAWTP." I am surprised that in the report there is not some accountability for the expenditure of the previous $10 Million and whether the Federal and Provincial contributions were obtained. The report states: “This source of funding is now virtually exhausted, in large part due to the expenditure of $6.7 million to purchase a potential treatment plant site in Saanich East.” Why is there not some mention of how the remaining $3.3 Million has been spent? This proposed by law for $12 Million is actually another one percent of the currently estimated cost of land based treatment ($1.2 Billion).
The bylaw seems to expect that there will be Federal and Provincial Cost Sharing of this $12 Million. Does the agreement still stand and is there any assurance with current expected deficits for both Federal and Provincial Governments that these commitments will be funded?
To-day we are expecting the Premier to announce the new BC government cabinet. Apart from the Premier’s office there will be several Ministries who have an interest in the proposed $1.2 Billion CRD plan for Land Based Sewage Treatment. These Ministries current names (they may change) are the Ministry of Finance and the Ministry responsible for the Olympics, The Ministry of the Environment, and the Ministry of Community Development. This latter ministry is the one that provides the grants to municipalities and that has been promoting the integrated resource management approach. It has been somewhat confusing to note that the Minister of the Environment has provided the order to plan for treatment but the Ministry of Community Development has been promoting integrated resource management for this Mega project.
To finish up my five minutes - as you are aware I am someone who belongs to a group (RSTV) who will continue to remind you and other levels of government that the current two deep sea outfalls are highly effective in disposing of Victoria’s Liquid Waste. For the last thirty years this waste has been treated naturally by the Marine environment by a process similar to that achieved by a land based sewage treatment plant but with little energy use and no problem with sludge disposal. If you consider the overall environment the proposed land based treatment plants will have a greater adverse effect on the overall environment.
Thank you,
Dr Shaun Peck,
Member Responsible Sewage Treatment Victoria.
Wednesday, June 10, 2009
Dr Shaun Peck's comments to the CRD Liquid Waste Management Committee May 27th 2009.
My comments to-day are on agenda items 6, 7, 10.
Speaking firstly to agenda item 10. As a Victoria taxpayer I hope that you allow sufficient time at this meeting to discuss this important decision – the adoption of a wastewater treatment strategy.
The staff and consultants still have not come up with a bare bones, least cost option for your consideration that you requested by resolution on March 25th.
On March 25th the committee passed a motion “that staff be directed to request that the consultants prepare a least cost option for sewage treatment that will meet both the requirements of the Provincial Government and the standards agreed to by the Council of Environment Ministers.”
In my discussions with Civil Engineers – there is still a practical option of just building one traditional sewage treatment plant in the Westshore area. If you had this option in front of you, you would be able to see what cost savings could be made.
As the staff report indicates all the options – Options 1 A, B and C still include the Saanich East/North Oak Bay option using Membrane Filtration Technology. This technology has greater capital and operating costs and uses 2.4 times the energy of a conventional activated sludge technology. It is a given that there are lots of possibilities as to what you can recover – heat and energy etc but surely you have to consider the net costs of doing this. Several reports you have had before you have indicated that if you want to recover water and energy the capital and operating costs are higher and the net costs are higher because of the lack of offsetting revenue. Also where is the market demand for this possible revenue?
Surely you should ask for this option - particularly in these economic times - when you are looking at this huge expenditure. Taking the figure of $1.2 Billion. Particularly for those of you who represent the City of Victoria – do you realize that this cost is the equivalent of replacing the Johnson Street Bridge 19 times. Yes – at the cost reported this week of $63 Million you could rebuild the Johnson Street Bridge 19 times.
When you buy a car – do you buy all the “bells and whistles”, do you buy a new Cadillac? I read how diligent you are on Municipal Council’s to keep down any increases in the burden on the local taxpayers. This land based treatment is going to cost anywhere between $500 - $700 per household – however the cost will be added - directly onto taxes or as a separate sewer charge based on water use.
The Ministers letter of February 24th requested that you “Minimize total project costs to the taxpayer by maximizing economic and financial benefits, including beneficial use of resources and generation of offsetting revenue”. As I have stated previously you have had reports that have examined the beneficial use of resources and generating offsetting revenue – the reports however show that the net effect of revenue generation is greater capital and net operating costs.
On a positive note I would like to speak to agenda item 7 – the annual report of the source control program. There continues to be significant reductions in a range of contaminants, including metals and organic compounds, as reported in a recent study of wastewater and biosolids trends in the core area and on the Saanich Peninsula over the past 18 years.
This report reinforces the benefits of this program and emphasizes that the minimal effect on the marine environment continues to be reduced from the present two deep sea outfalls at Clover and MacCaulay points.
Secondary treatment would not be as effective at removing some of the target chemicals (such as mercury) that have proven to be done with the source control program.
Agenda item 6 – the report of the Harbours Environmental action plan is another good news report where just $229,146 a year is being spent to reduce the contamination of the harbours. It should be noted that the sediments in the harbours are much more highly contaminated than those at the end of the two deep sea outfalls.
As a final note – As I have mentioned in past presentations please request staff and your consultants to examine the overall environmental impact of the proposed land based sewage treatment plants compared with the two deep sea outfalls that enable natural sewage treatment. It is the total impact on the environment that needs to be compared. We need to know not just that there will be efforts to reduce Green House Gas emissions but how much greater they will be compared with any emissions from the present practice.
Thank you,
Dr Shaun Peck,
Public Health Consultant,
Member of Responsible Sewage Treatment Victoria. May 27, 2009
Dr Peck's presentation to the CRD's Liquid Waste Management Committee May 13th 2009.
Now that we have a newly elected Provincial Government I am expecting you to have a closer look at the current plans for increased sewage treatment. Surely you should request the Minister of Environment for further planning time to meet the deadlines that have been requested. No choice yet has been made on the number of plants, the technology to be used or the method of sludge disposal.
As you are aware I belong to a group called Responsible Sewage Treatment Victoria. I would like to remind you that based on our best assessment from Public Health Officials and Marine Scientists that the current two deep sea outfalls which discharge screened liquid waste into the Juan de Fuca Strait are highly effective in ensuring there is no public health risk and that the effect on the marine environment is minimal. Please compare these facts to the fact that there significant effects on the environment from building land based sewage treatment plants. Just last Sunday, neighbours toured Haro Woods and there was a lot of anger expressed at the thought of clearcutting that neighbourhood forest, just for a risky, unnecessary sewage plant.
There is no need to spend $1-$2 Billion of taxpayers money now for no clear benefit. There are much greater priorities that will benefit our communities such as enhancing the Source Control Program, fixing the storm drain problems or investing in Light Rapid Transit to the Western Communities, Health Facilities, Housing for the homeless or even a new Johnson Street Bridge.
Speaking to agenda items 6 and 9 I have the following comments:
The Sustainability Assessment Framework does not include a comparison with the current natural treatment that occurs with the screened effluent being discharged through two deep sea outfalls. For the sake of understanding the social/community, environmental and public health impacts of land based treatment plants surely you should be requesting this. Without this comparison it not possible to determine the benefits of land based treatment. Why is it needed and what will be the benefits? This is not too much to ask. After all, as taxpayers we are going to have to pay for it.
I am concerned that consultants are increasingly likely to confuse you with changing names – SAF to replace TBL and MOAA, RIA etc. They sound impressive but are simply industry assessment processes that have assumptions throughout them that may be difficult to understand.
I am unimpressed with the efforts to provide the least cost option that you requested by resolution at the March 25th meeting. Why is there not included the option for only one new plant in the South Colwood area? Could not the system be designed without the North Oak Bay/ East Saanich site? Is it really justifiable to include the Membrane Filtration Technology at the East Saanich site? It would be nice to do but this technology has greater capital and operating costs and uses 2.4 times the energy of conventional activated sludge technology.
From the perspective of energy and water reclamation – from my reading of several reports that you have had before you this is only going to result in an add on cost – not a way of reducing the burden on the taxpayer. Unfortunately the Integrated Resource Management report by Fidelis Resource group has been promoted thoughout the region even though reports you have had (including the Peer Review) have largely discredited any economic or environmental benefit that will be achieved from their recommendations.
It was disappointing to find that there was no coherent response from the peer review team to the queries from committee members at the last meeting concerning potential environmental impacts or benefits from the project. In their verbal responses the peer review team seemed to agree that there would be no environmental benefit and that any potential benefit had not yet been identified or measured.
Commenting on greenhouse gas concerns – I would draw your attention to the Peer Review Panel - Appendix H: “The current CRD discharge of screened wastewater to the ocean has little impact on fossil fuel carbon except for that associated with energy use for pumping. There is likely no associated methane production with the largely aerobic ocean conditions and rapid currents.”
There is no need, let alone any urgency, from a public health or environmental benefit to build land based treatment plants. I urge you to ensure that there has been a more diligent process that provides the least cost option. This process must include an evaluation of the present system as a baseline. Otherwise how are we to know what problem(s) we are trying to solve or what we will receive for this massive expenditure of tax dollars. It is difficult to imagine how you are going to achieve a carefully prepared plan by the current Minister ordered deadlines. Surely you should be requesting the Minister of Environment for an extension of the planning deadlines.
Thank you,
Dr Shaun Peck- May 13th 2009
Dr Peck's presentation to the CRD Liquid Waste Management Committee March 11th 2009.
I am speaking to-day mainly as a concerned tax payer and as someone who has closely followed the planning for Sewage Treatment since 2006 and before that for 20 years.
I am pleased to see many of the comments in to-days preliminary Peer review report. The Peer review team has further discredited the IRM report and is consistent with the critiques that were published by the Ministry of Community Development, and the consultant’s reports of two weeks ago which provide evidence that there is lack of credibility of the IRM report from a Civil Engineering perspective and from an economic perspective. None of the recovery options have offered a net benefit, but only a small off-setting cost recovery.
It appears at this time that the Liquid Waste Management Committee has before it three options for considerations designed to meet the Provincial Ministers order. Should not there be a fourth option developed?
As a concerned taxpayer I naturally want to focus on what will be the minimum impact on our taxes – whether it is Local (Municipal), Provincial or Federal taxes. You have been hearing a fair amount about great ideas from Sweden. Did you know that Sweden has the second highest overall tax rate in the world (after Denmark)? That being said I hear that the visitors from Sweden in the last two weeks clearly indicated that the trend in their country is away from distributed wastewater plants, which are under consideration in the CRD’s options, towards more centralised treatment plants.
As we are all aware at this time there is a global economic downturn and every level of Government, every business and every individual is having to rethink their future spending plans – even to the point of Provincial and Federal Governments running and increasing their deficits.
Why am I mentioning this in regards to the CRD’s Liquid Waste Management Plans? Because there are some questions that I have not heard being asked that seem to me and the Civil Engineers I have talked to that need to be asked.
I urge you to ask more questions and require the development of bare bones Cost Option. When the “Path Forward” document was produced in 2007 with the four treatment plant sites, there was little discussion as to whether it was the least cost option. Should not this be presented to you? I am sure the Federal and Provincial Governments would welcome a least cost option being presented for discussion.
The following are some of questions I suggest you should be asking of the current least cost option that was in the “Path Forward” document:
- Why is it necessary to go with the membrane filtration technology instead of conventional secondary treatment?
- Why is it necessary to have three plants – Saanich East, Macaulay/McLoughlin and the Western Communities with a wet weather flow plant at Clover point? Would one main plant be sufficient?
- Would the existing Trunk Sewer Lines be able manage the dry and wet weather flow with an increasing population so that the discharges can be accommodated at the Macaulay/ McLoughlin and Clover point? Clearly the amount of land available is a factor.
- If larger pipes were needed from the Western Communities as the population increases, what would be the costs compared with building distributed plants?
- What is the least cost option that will meet the Standards that have recently been proclaimed by the Canadian Council of Environment Ministers? The standard calls for levels of Total Suspended Solids, Biological Oxygen demand and Total Residual Chlorine to be met as the standard claims are needed to protect Public Health and the Environment.
- What is the least cost option for dealing with the sludge – even with energy recovery, if there is a net benefit? This benefit should be measured against both the operating and the capital cost amortisation.
- Are you satisfied that even option one, in the “Path Forward” has had enough analysis – due diligence - to make it the preferred least cost option?
To summarise – in my view taxpayers will hope that you have asked these type of questions particularly in this time of a global economic downturn. You are at this time committed to meet the Provincial Minister of Environments order to plan for treatment and the Standard that has been proclaimed by the Council of Environment Ministers.
So - I urge you before making any decision on the current options that have been presented by the staff and the consultants to require a bare bones least cost option for review, to determine if it meets the Provincial order and the National Standards before proceeding any further. Could the peer review team help you with this?
Dr Shaun Peck,
Public Health Consultant.
Member Responsible Sewage Treatment Victoria
Dr Peck's presentation to the CRD's Liquid Waste Management Committee February 25th 2009.
The February 11th report on “Biosolids Organic Residuals Strategy” evaluation presented you with a preferred strategy 1d which called for wastewater solid’s anaerobic digestion. This option calls for some of the solids being spread on the land in a “Willow Coppice” program that would potentially need 1800 hectacres of farmland every 20-30 years. When the trees are harvested the wood chips may be able to be used as a biofuel. It is stated that the dried biosolids could provide a substitute for coal in cement kilns. This option would cost around $185 Million Net Present Value.
If it has been dewatered there will be 20 Truck loads a week of sludge from the treatment plants spread on the land.
With to-days effective two deep sea outfalls there are only about 24 hectacres of the ocean floor where the ocean sediments are affected by the effluent. That effluent does in effect undergo secondary aerobic (with oxygen) treatment over a period of time in the ocean. There is a minimal impact that has positive aspects to it – enrichment of the sea floor 60 meters below the ocean surface.
24 hectacres is a lot less than 1800 hectacres. How is the CRD going to acquire or have access to this 1800 hectares? We heard at the last meeting that 200 Hectares is the equivalent to 5 Victoria Golf Courses. 1800 hectacres is 45 golf courses! Is the farmland or forest land available for this? Where will it be? Will the neighbours welcome it? We have heard of the allegations of serious problems in Ontario with spreading sewage waste on farmland.
The CRD originally estimated that biosolids management would cost $85 Million. Now we have an option that is going to cost in the region of $185 Million - more than double.
I have doubts about what has been presented about the carbon offsets. If something like 10,000 tons of dewatered sludge per year is going to be produced and half of it burnt in cement plants you should be aware that the BC Tire recycling program already burns 11,677 Tons of tires a year - one third of the tires recycled - in these cement kilns. Is it intended to replace this with the 10,000 tons of dried biosolids? Are the carbon offsets realistic – is it not just a substitution with no real gain for the global environment?
We must concern ourselves with the CO2 that is generated from fossil fuels to process and dispose of the sewage. Right now this is at a minimum. Any land based treatment (regardless of resource recovery) will require more not less energy and ultimately increase our carbon footprint. I hope that the energy costs for dewatering the sludge have been included in the cost estimates.
To-days report on “Distributed Waste Water management strategies” verifies the critiques that were published by the Ministry of Community Development of the Integrated Resource Management (IRM) proposal. My sense is that as a result of the promotion of this concept everyone thinks it is the right thing to do. I have no problem with the general concept but I would recommend that if you have not already done so you review the published Technical Advisory Committee and the Peer Review comments and critique of the IRM report.
Changing now from resource recovery to water recovery – which is mentioned in to-day’s report. It really does not make sense to plan for water recovery when our own Water Commission does not project the need for more water for 50 years and even then a large new watershed area has been set aside. What would the cost of the recovered water be per household compared with the present cost?
As a taxpayer and considering the impact on ones grandchildren’s future – increased taxes or sewer charges will effect their opportunities for day care, recreation etc - if we really are going to build land based sewage treatment plants I hope you choose the least cost option. When there is no demonstrated benefit, $1.2 billion makes no sense and $2 billion makes even less sense!
The following plea is not new – there is frequent mention of the “triple bottom line approach.” The triple bottom line approach, like cost-benefit, must demonstrate some sort of benefit and must include all options.
So far this approach has not included a comparison of the environmental impact of the present two deep sea outfalls.
Please keep asking questions of the staff and consultants about the cost-benefits of land based sewage treatment and of the environmental impact of land based treatment plants compared with the present deep sea out falls. There will be negligible benefit to the marine environment, harm to the land environment and huge costs. Land based treatment will not deal effectively with the genuine issues the “toxics” in the sewage and the storm drains and beach overflows.
My hope is that as you continue to receive these reports on the realities – the environmental impact, the lack of effectiveness of dealing with “toxics” of concern, and the lack of clear benefit - and as you “Take Control of the Sewage Plan” as yesterdays Times Colonist editorial suggested - that you will come to the conclusion that the Minister’s order to treat needs to be challenged. I urge you to consider in the future, when the planning and its impact becomes clearer you may need to challenge the Minister’s order on the grounds that he has ordered Victoria to cause environmental harm, misusing his legislated authority to protect our natural environment.
Thank you,
Dr Shaun Peck,
Public Health Consulting,
Member of Responsible Sewage Treatment Victoria
Dr Peck's Presentation to the CRD Liquid Waste Management Committee January 8th 2009.
My presentation is about two reports before you to-day.
Firstly - Agenda item 5 - “Characterisation of Waste Water” calls for funding for monitoring Suspended Solids, BOD, Ammonia, pH and Fecal Coliforms in order to characterize the Current Liquid Waste and plan treatment accordingly.
I find it quite amazing that those substances generally known as contaminants, including metals, pharmaceuticals and other chemicals, and that have been of concern to many people (including the Minister of Environment), are not included in this proposed characterization of waste water. Measurement of these contaminants would greatly help determine what will be in the sludge that will be produced by a sewage treatment plant and how effective the sewage treatment will be.
I am aware that the staff report measurements may be needed to plan basic primary and secondary sewage treatment. These substances are however not of public health or environmental concern through the present practice of disposing of the Core Area's liquid waste through our two deep long outfalls into the marine receiving environment of Juan de Fuca Strait.
They would be of concern if the liquid waste was being discharged into fresh water or any body of water where there is lack of dispersion which occurs with our deep sea outfalls.
I request you seek clarification on why the contaminants of concern are not included in the “Characterisation of Waste Water” sampling.
Secondly - Agenda item 7 – I have eight additional questions for your consideration on the report on “Peer review questions”. I find the questions in the staff report too generalized and may result in very unspecific answers. (Such terms as “reasonable”, “adequate”, “flexible”, “adaptable”, “appropriate” are much too vague and not quantifiable).
Therefore, I recommend you include additional questions such as the following:
- Has the consultant taken into account the successful water conservation measures that are occurring in the CRD in the population projections and water use? (This would have a significant bearing on the size of any treatment plants planned).
- For any water reclamation proposal has the consultant taken into account the fact that the CRD Water District projects 50 year adequacy of water supply for the Region?
- What will the effect be on public health and the marine environment during wet weather flows? (As you are aware plants are usually designed just to treat 2 times dry weather flows. In some areas – such as Oak Bay after heavy rainfall – like yesterday - there is 10 times dry weather flow).
- What will be the predicted concentrations of contaminants of concern – metals, pharmaceuticals and other chemicals in the biosolids (treated sludge) compared with that which is present in the Marine Environment? (Secondary Treatment concentrates many of these chemicals leading to a contaminated waste – known also as Sludge or when treated as Biosolids).
- What effect will the most economic option have on the overall environment (air, land and marine) compared with the present practice of discharge through the two deep sea outfalls? (I purposely say – most economic - because I am hoping you will come to accept that there is unlikely to be any clearly defined benefit, apart from an intangiable or “feel good” benefit, of this expenditure. I quote from the 2007 Marine Monitoring report. “The overall conclusion was that the impact on the receiving environment is limited both spacially and temporally. The areas of impact are generally within 200m of Macaulay point and 100m of Clover point”.
- What percentage of the plant construction costs will be covered by the revenues from resource, energy, or heat recovery schemes and will these revenues offset the extra operating costs and capital costs (amortized) for the technology required? (We have heard a lot about Integrated Resource Management but surely it has got to be a net cost benefit). “Cost-effective implementation of the IRM approach necessitates careful evaluation of the costs and benefits of each element of resource recovery.”
- Will the proposals be compliant with the Provinces Greenhouse Gas Reduction Targets Act (GGRTA) and the recently proclaimed Emission Offset Regulation? That is to say will the project’s construction and operating emissions achieve carbon neutrality? (I might remind you that to manufacture one ton of cement produces one ton of Carbon Dioxide. It is likely that hundreds of tons of concrete – that uses cement powder - will be required during construction of sewage treatment plants).
- Have improved opportunities for enhanced source control, and fixing the contamination of the marine environment from the storm drains been included in the plan?
Dr Shaun Peck
Public Health Consultant
Member of Responsible Sewage Treatment Victoria.